Privacy & Cookies Policy - Disability Information Scotland

Privacy Notice

Introduction to privacy notice

What is personal data?

Our processing

Client confidentiality

Cookie Policy

Introduction to cookies

We use the following cookies

When is your consent required for cookies?

Introduction to privacy notice

Disability Information Scotland (also referred to as ‘the company’, ‘we’, ‘our’ or ‘us’) is the Data Controller over any personal data we process about you for the purposes set out in this Privacy Notice. This notice outlines what personal data we collect and process about you when you engage with our services, which explain below.

The categories of data subjects whose personal data is covered by this privacy notice include clients contacting our helpline via telephone, text and email, attendees of our online training, and representatives of organisations wishing to be added to the Scottish Disability Directory.

Please read through the privacy notice to understand how we use and process your personal data obtained. If you have any concerns about our processing of your personal data or have a general enquiry in relation to data protection, please contact our Data Protection Officer at info@disabilityscot.org.uk

What is personal data?

Personal Data: means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Special Category Data: means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

When we use the term ‘personal data’ we mean both personal data and special category data.

Our Processing

Personal Data is collected in several different ways dependent on your interaction with us. The list below sets out what personal data we process about you, where we get it from, why we use it, our legal basis and who we share it with.

Client Confidentiality

When you call, email, or text our helpline for information, you have the choice to remain anonymous.

We may ask you some additional questions to help inform the work we do, and to help us identify demographics most in need of our support.

How we use your data

1. To respond to enquiries to our helpline (telephone, email, and text).

What data is this? Name, contact information.
Where do we get this data from? You, the data subject, directly.
The legal basis for us holding this information? Legitimate Interest – where information is necessary for the purposes of providing a response i.e. email address and contact telephone number.
Will we share it as set out above? With your consent, we may share information with third party organisations such as your local authority and ask them to contact you.

2. To create an identifiable record of information provided with a view of further correspondence taking place

What Data is this? Name, contact information, personal circumstances
Where do we get this data from? You, the data subject, directly
The legal basis for us holding this information? Consent – you will be given the choice to remain anonymous during your interactions with us
Will we share it as set out above? No

3. To follow up with you again in the future for evaluation purposes

What Data is this? Name, contact information, your feedback
Where do we get this data from? You, the data subject, directly
The legal basis for us holding this information? Consent – you will be given the choice to participate in our evaluation
Will we share it as set out above? No

4. To inform our strategy and approach to reaching individuals who require our support

What Data is this? Age, location
Where do we get this data from? You, the data subject, directly
The legal basis for us holding this information? Consent – you have the choice to provide this supplementary information when you contact us
Will we share it as set out above? No

5. To contact you in relation to your directory request

What Data is this? Name, telephone, email
Where do we get this data from? You, the data subject, directly
The legal basis for us holding this information? Legitimate Interest – this information is necessary to assess your request
Will we share it as set out above? No

6. To provide you with access to our training modules

What Data is this? Name, email, username
Where do we get this data from? You, the data subject, directly
The legal basis for us holding this information? Contract – this information is necessary to fulfil our training service to you
Will we share it as set out above? No

7. To provide you with a certificate of completion if you complete one of our training modules.

What Data is this? Name, email
Where do we get this data from? You, the data subject, directly
The legal basis for us holding this information? Legitimate Interest – so you to receive evidence that you have completed our training
Will we share it as set out above? No

8. To provide you with our direct marketing communications by email or text.

What Data is this? Name, email and telephone number
Where do we get this data from? You, the data subject, directly
The legal basis for us holding this information? Consent – you have the choice to be added to our mailing list
Will we share it as set out above? No

How we share your personal data

We use third party service providers to support some of our operations. We have necessary contractual and other provisions in place to ensure your personal data is kept secure.

We may share your personal data where it is necessary, there is a legitimate need to do so, or where we have your consent. This includes:

Contacting your local authority on your behalf to request that they contact you

Security

We treat the security of your personal data seriously and enforce strong physical and electronic safeguards while in storage and in transit.

Retention

We shall keep your personal data for as long as is necessary and in accordance with our Retention Policy. We retain general correspondence and emails for six years.

Your rights

You have certain rights under data protection law, which are summarised below. You can exercise these by contacting our DPO at info@disabilityscot.org.uk

Right of access to the data we process about you
Right to rectification of any data we process that may be incorrect
Right to erasure of data we process about you
Right to restrict processing of data we process about you
Right to object to the Bureau processing your data
Right to data portability
Right not to be subject to automated decision-making and profiling

You have the right to lodge a complaint with the Information Commissioners Office (ICO) if you think that we have infringed your rights. You can find more information about reporting a matter to the ICO at the following link: https://ico.org.uk/

Call Recording

Disability Information Scotland may record telephone calls made to and from the organisation. Call recordings are used for the following purposes:

To maintain accurate and reliable records of information provided.
To support effective case management and continuity of service.
To assist staff when dealing with complex, challenging or sensitive calls.
To help resolve complaints, disputes or concerns.
To support safeguarding, staff wellbeing and quality assurance.
For training purposes where appropriate.

Call recording is carried out in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Lawful Basis for Processing

The lawful bases relied upon for recording calls and processing related personal data are:

Legitimate interests – to deliver a safe, effective and consistent information service; to safeguard staff and service users; to maintain accurate records, and to manage complex or difficult interactions.
Legal obligations – where record keeping is required for safeguarding, complaint handling, or regulatory compliance.

Where special category data (for example, information relating to health or disability) is disclosed during calls, it is processed with additional care and appropriate safeguards.

Retention of Call Recordings

Call recordings are retained for six months from the date of the call.

After this period, recordings are securely deleted unless there is a lawful reason to retain them for longer, such as where a recording is required for an ongoing complaint, safeguarding concern, investigation or legal matter.

Retention and Use of Telephone Numbers

Disability Information Scotland retains callers’ telephone numbers for identification and case management purposes.

Callers are not required to provide their name.
Telephone numbers are used as an identifier to:
Locate and retrieve case records quickly.
Link calls to existing case notes.
Support continuity of information and support.
Enable staff to review previous interactions, particularly where calls have been complex, challenging or distressing.

Telephone numbers are stored securely within Disability Information Scotland’s case management system, Charitylog, and are accessible only to authorised staff. Telephone numbers are not used for marketing purposes unless explicit consent has been given.

Data Security and Access

All call recordings and telephone number data held by Disability Information Scotland are:

Stored securely
Accessed only by authorised staff members
Protected by appropriate technical and organisational security measures.

Staff receive training on confidentiality, data protection, information governance and are required to follow internal policies at all times.

Individual Rights

Individuals have rights under data protection law, including the right to:

Request access to their personal data
Request correction of inaccurate data
Request erasure or restriction of processing, where applicable
Object to processing carried out under legitimate interests

Requests can be made in line with Disability Information Scotland’s data protection and subject access procedures.

Website

Our website may contain links to other websites. Please note that we have no control of websites outside our domain. We are not responsible for the protection and privacy of any sensitive information provided to a website linked to disabilityscot.org.uk.

Changes

We reserve the right to amend this privacy notice from time to time.

Cookie Policy

Introduction to cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

Strictly necessary cookies: These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

Functional cookies: These cookies are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Analytical or performance cookies: These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

The rules which apply to the use of cookies are defined within the Privacy and Electronic Communications Regulations (‘PECR’) which require that:

We tell you what cookies we use;
What these cookies are doing and why; and
We ask for your consent to store any cookies on your device, that are not essential via our cookie banner.

When you visit our website for the first time, we ask for your consent to store non-essential cookies on your device. You can update your cookie preferences at any time by clicking the blue link at the bottom left of the page.

You can find more information about the individual cookies we use and the purposes for which we use them in the list below:

Name cookieyes-consent

Type Necessary
Purpose CookieYes sets this cookie to remember users’ consent preferences so that their preferences are respected on their subsequent visits to this site. It does not collect or store any personal information of the site visitors.
Duration 1 year

Name Wordpress_test_cookie

Type Necessary
Purpose This cookie is used to check if the cookies are enabled on the users’ browser.
Duration Session

Name __cf_bm

Type Functional
Purpose This cookie, set by Coudfare, is used to support Cloudfare Bot Management.
Duration 30 Minutes

Name _ga

Type Analytical
Purpose The _ga cookie, installed by Google Analytics, calculates visitor, session and campaign data and also keeps track of site usage for the site’s analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognize unique visitors.
Duration 2 years

Name _gid

Type Analytical
Purpose Installed by Google Analytics, _gid cookie stores information on how visitors use a website, while also creating an analytics report of the website’s performance. Some of the data that are collected include the number of visitors, their source, and the pages they visit anonymously.

Duration 1 day

Name _gat_gtag_UA_70926537_1

Type Analytical
Purpose Set by Google to distinguish users.
Duration 1 minute

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.This cookies policy may be amended by us at any time. Please check this page periodically so that you are aware of any changes.

Cookie Policy last updated October 2024.

Call policy added January 2026